Self-Regulatory Organizations; Municipal Securities Rulemaking Board; Order Granting Approval of a Proposed Rule Change To Amend MSRB Form G-45 To Collect Additional Data About the Transactional Fees Primarily Assessed by Programs Established To Implement the ABLE Act, 59148-59151 [2017-26909]
Download as PDF
59148
Federal Register / Vol. 82, No. 239 / Thursday, December 14, 2017 / Notices
sradovich on DSK3GMQ082PROD with NOTICES
Burden on Competition and Barriers to
Entry
(12) Commenters’ views as to whether
the allocation of 75% of CAT costs to
Industry Members (other than Execution
Venue ATSs) imposes any burdens on
competition to Industry Members,
including views on what baseline
competitive landscape the Commission
should consider when analyzing the
proposed allocation of CAT costs.
(13) Commenters’ views on the
burdens on competition, including the
relevant markets and services and the
impact of such burdens on the baseline
competitive landscape in those relevant
markets and services.
(14) Commenters’ views on any
potential burdens imposed by the fees
on competition between and among
CAT Reporters, including views on
which baseline markets and services the
fees could have competitive effects on
and whether the fees are designed to
minimize such effects.
(15) Commenters’ general views on
the impact of the proposed fees on
economies of scale and barriers to entry.
(16) Commenters’ views on the
baseline economies of scale and barriers
to entry for Industry Members and
Execution Venues and the relevant
markets and services over which these
economies of scale and barriers to entry
exist.
(17) Commenters’ views as to whether
a tiered fee structure necessarily results
in less active tiers paying more per unit
than those in more active tiers, thus
creating economies of scale, with
supporting information if possible.
(18) Commenters’ views as to how the
level of the fees for the least active tiers
would or would not affect barriers to
entry.
(19) Commenters’ views on whether
the difference between the cost per unit
(messages or market share) in less active
tiers compared to the cost per unit in
more active tiers creates regulatory
economies of scale that favor larger
competitors and, if so:
(a) How those economies of scale
compare to operational economies of
scale; and
(b) Whether those economies of scale
reduce or increase the current
advantages enjoyed by larger
competitors or otherwise alter the
competitive landscape.
(20) Commenters’ views on whether
the fees could affect competition
between and among national securities
exchanges and FINRA, in light of the
fact that implementation of the fees does
not require the unanimous consent of all
such entities, and, specifically:
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(a) Whether any of the national
securities exchanges or FINRA are
disadvantaged by the fees; and
(b) If so, whether any such
disadvantages would be of a magnitude
that would alter the competitive
landscape.
(21) Commenters’ views on any
potential burden imposed by the fees on
competitive quoting and other liquidity
provision in the market, including,
specifically:
(a) Commenters’ views on the kinds of
disincentives that discourage liquidity
provision and/or disincentives that the
Commission should consider in its
analysis;
(b) Commenters’ views as to whether
the fees could disincentivize the
provision of liquidity; and
(c) Commenters’ views as to whether
the fees limit any disincentives to
provide liquidity.
(22) Commenters’ views as to whether
the amendment adequately responds to
and/or addresses comments received on
related filings.
Electronic Comments
• Use the Commission’s internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an email to rule-comments@
sec.gov. Please include File Number SR–
NYSEMKT–2017–26 on the subject line.
Paper Comments
• Send paper comments in triplicate
to Brent J. Fields, Secretary, Securities
and Exchange Commission, 100 F Street
NE, Washington, DC 20549–1090.
All submissions should refer to File
Number SR–NYSEMKT–2017–26. This
file number should be included on the
subject line if email is used. To help the
Commission process and review your
comments more efficiently, please use
only one method. The Commission will
post all comments on the Commission’s
internet website (https://www.sec.gov/
rules/sro.shtml). Copies of the
submission, all subsequent
amendments, all written statements
with respect to the proposed rule
change that are filed with the
Commission, and all written
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for website viewing and
printing in the Commission’s Public
Reference Room, 100 F Street NE,
Washington, DC 20549 on official
business days between the hours of
10:00 a.m. and 3:00 p.m. Copies of the
filing also will be available for
PO 00000
Frm 00357
Fmt 4703
Sfmt 4703
inspection and copying at the principal
office of the Exchange. All comments
received will be posted without change.
Persons submitting comments are
cautioned that we do not redact or edit
personal identifying information from
comment submissions. You should
submit only information that you wish
to make available publicly. All
submissions should refer to File
Number SR–NYSEMKT–2017–26 and
should be submitted on or before
January 4, 2018.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.101
Robert W. Errett,
Deputy Secretary.
[FR Doc. 2017–27022 Filed 12–13–17; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–82238; File No. SR–MSRB–
2017–08]
Self-Regulatory Organizations;
Municipal Securities Rulemaking
Board; Order Granting Approval of a
Proposed Rule Change To Amend
MSRB Form G–45 To Collect
Additional Data About the
Transactional Fees Primarily Assessed
by Programs Established To
Implement the ABLE Act
December 8, 2017.
I. Introduction
On October 13, 2017, the Municipal
Securities Rulemaking Board (the
‘‘MSRB’’ or ‘‘Board’’) filed with the
Securities and Exchange Commission
(the ‘‘SEC’’ or ‘‘Commission’’), pursuant
to Section 19(b)(1) of the Securities
Exchange Act of 1934 (‘‘Act’’) 1 and Rule
19b–4 thereunder,2 a proposed rule
change to amend MSRB Form G–45
under MSRB Rule G–45, on reporting of
information on municipal fund
securities,3 to collect additional data
about the transactional fees primarily
assessed by programs established to
implement the Stephen Beck, Jr.,
Achieving a Better Life Experience Act
of 2014 (the ‘‘ABLE Act’’ and an ‘‘ABLE
program’’) (the ‘‘proposed rule
change’’).4 The proposed rule change
101 17
CFR 200.30–3(a)(12).
U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
3 Form G–45 is an electronic form on which
submissions of the information required by Rule
G–45 are made to the MSRB.
4 The ABLE Act was enacted on December 19,
2014 as part of The Tax Increase Prevention Act of
2014 (Pub. L. 113–295).
1 15
E:\FR\FM\14DEN1.SGM
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Federal Register / Vol. 82, No. 239 / Thursday, December 14, 2017 / Notices
was published for comment in the
Federal Register on October 27, 2017.5
The Commission received one
comment letter on the proposed rule
change.6 On December 1, 2017, the
MSRB responded to the comments
received by the Commission.7
sradovich on DSK3GMQ082PROD with NOTICES
II. Description of Proposed Rule Change
In the Notice of Filing, the MSRB
stated that the proposed rule change
would amend Form G–45 to collect
additional information relating to fees
and expenses to help ensure that the
MSRB continues to receive
comprehensive information regarding
ABLE programs and 529 college savings
plans.8 The MSRB stated that this data
would enhance the MSRB’s
understanding of the markets for ABLE
programs and 529 college savings plans,
including the differences among such
programs or plans.9 Further, the MSRB
stated that the additional fee and
expense information would assist the
MSRB in fulfilling its investor
protection mission.10 The MSRB also
stated that the information about fees
and expenses would continue to be
submitted in a format that is consistent
with the disclosure principles of the
College Savings Plan Network
(‘‘CSPN’’), an affiliate of the National
Association of State Treasurers, which,
the MSRB added, commenters on
previous MSRB rulemaking proposals
relating to MSRB Form G–45 have stated
is the industry norm.11
As further described by the MSRB in
the Notice of Filing, under the proposed
rule change, an underwriter to an ABLE
program or a 529 college savings plan
would be required to submit data on
Form G–45 about the following
additional fees and expenses, as
applicable:
• account opening fee;
• investment administration fee;
• change in account owner fee;
• cancellation/withdrawal fee;
• change in investment option/
transfer fee;
5 Securities Exchange Act Release No. 81921
(October 23, 2017) (the ‘‘Notice of Filing’’), 82 FR
49908 (October 27, 2017).
6 See Letter to Secretary, Commission, from Leslie
Norwood, Managing Director and Associate General
Counsel, and Bernard Canepa, Vice President and
Assistant General Counsel, Securities Industry and
Financial Markets Association (‘‘SIFMA’’), dated
November 17, 2017 (the ‘‘SIFMA Letter’’).
7 See Letter to Secretary, Commission, from
Pamela K. Ellis, Associate General Counsel, MSRB,
dated December 1, 2017 (the ‘‘MSRB Response
Letter’’), available at https://www.sec.gov/
comments/sr-msrb-2017-08/msrb201708-2743045161576.pdf .
8 See Notice of Filing.
9 Id.
10 Id.
11 Id.
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• rollover fee;
• returned excess aggregate
contributions fee;
• rejected ACH or EFT fee;
• overnight delivery fee;
• in-network ATM fee;
• out-of-network ATM fee;
• ATM mini statement fee;
• international POS/ATM transaction
fee;
• foreign transaction fee;
• overdraft fee;
• copy of check or statement fee (per
request);
• copy of check images mailed with
monthly statement fee;
• check fee (i.e., fee for blank checks);
• returned check fee;
• checking account option fee;
• re-issue of disbursement check fee;
• stop payment fee;
• debit card fee;
• debit card replacement fee;
• outgoing wire fee;
• expedited debit card rush delivery
fee;
• paper fee; and
• miscellaneous fee (to address any
miscellaneous transactional fee that is
not otherwise specified on Form G–
45).12
In addition, under the proposed rule
change, the MSRB stated that it would
collect data about any variance in the
annual account maintenance fee due to
the residency of the account owner.13
The MSRB also stated that the proposed
rule would apply to underwriters to
ABLE programs as well as to
underwriters to 529 college savings
plans.14 The MSRB, however, stated
that it anticipates that most of the data
that would be collected by the proposed
rule change would relate to ABLE
programs.15 The MSRB also noted that
it believes that 529 college savings plans
generally do not assess the fees and
charges that are the subject of this
proposed rule change.16
The MSRB requested in the Notice of
Filing that the proposed rule change be
approved with an effective date of June
30, 2018.17
III. Summary of Comments Received
and MSRB’s Responses to Comments
As noted previously, the Commission
received one comment letter on the
proposed rule change, as well as the
MSRB Response Letter. The commenter,
SIFMA, stated that it was ‘‘supportive of
the MSRB’s efforts to fully understand
the ABLE programs and 529 college
savings plans market and fulfill its
mission’’ but believed that municipal
securities dealers who underwrite ABLE
programs and 529 college savings plans
‘‘should only be required to submit the
information required by Form G–45 to
the extent it is within their possession,
custody, or control’’.18 SIFMA also
stated that the MSRB should be mindful
of the possibility that additional
regulatory requirements such as the
proposed rule change could increase
costs to investors in dealer-sold 529
college savings plans and ABLE
programs versus direct-sold programs
that are not regulated by the MSRB.19
The MSRB stated that it believes the
proposed rule change is consistent with
its statutory mandate and has responded
to the comments, as discussed below.20
1. Submission of Information Within
Custody of Dealer
SIFMA stated that some of the
information about fees that underwriters
would be required to submit on MSRB
Form G–45, under the proposed rule
change, may be contained in ABLE
program or 529 college savings plan
disclosure documents and suggested
that those underwriters could provide
hyperlinks to those documents to the
MSRB.21 The MSRB responded by
stating that even if some of the
information required to be submitted on
MSRB Form G–45 were contained in
those ABLE program or 529 college
savings plan disclosure documents, that
the information would not be published
in a uniform electronic format that
would allow for the MSRB’s efficient
analysis or comparison of such
information.22 The MSRB noted that, at
this time, there is no requirement that
state issuers prepare those disclosure
documents in a uniform format and,
unlike for 529 college savings plans,
there are not even voluntary disclosure
principles for state issuers in the
preparation of their disclosure
documents that are applicable to ABLE
programs.23 As result, the MSRB stated,
it is even more likely that the
information in the ABLE program
disclosure documents would not be
presented in a uniform format that
would allow the MSRB to readily
analyze and compare ABLE programs.24
In addition, the MSRB stated that
referencing the ABLE program or 529
18 See
12 Id.
13 Id.
20 See
14 Id.
SIFMA Letter.
19 Id.
21 See
MSRB Response Letter.
SIFMA Letter.
22 See MSRB Response Letter.
23 Id.
24 Id.
15 Id.
16 Id.
17 Id.
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Federal Register / Vol. 82, No. 239 / Thursday, December 14, 2017 / Notices
sradovich on DSK3GMQ082PROD with NOTICES
college savings plan disclosure
documents would not meet the MSRB’s
regulatory need because the data
provided to the MSRB must be in a
uniform electronic format that can be
aggregated and analyzed.25 The MSRB
acknowledged that the proposed rule
change would result in some up-front
costs to underwriters due to technical
changes to underwriters’ reporting
systems, but the MSRB stated that those
costs should mostly be one-time only
costs and that the cumulative benefits of
receiving data in a uniform electronic
format should exceed the upfront costs
over time.26
2. Applicability of Proposed Rule
Change to Advisor-Sold and Direct-Sold
ABLE Programs and 529 College Savings
Plans
SIFMA suggested that the duty to
submit information about the fees
assessed by ABLE programs and 529
college savings plans on MSRB Form G–
45 would create an undue burden
because, in SIFMA’s view, the MSRB’s
jurisdiction is limited to underwriters to
dealer-sold ABLE programs or 529
college savings plans.27 The MSRB
responded by stating that such an undue
burden on competition would not exist
because the MSRB believes it has
jurisdiction over all underwriters of
ABLE programs and 529 college savings
plans.28 The MSRB stated that it has
jurisdiction over underwriters to all 529
college savings plans, regardless of the
marketing channel through which such
plans are sold (whether sold with the
advice of a dealer, i.e., ‘‘advisor-sold,’’
or without the advice of a dealer, i.e.,
‘‘direct-sold’’), and this view has equal
application to similar ABLE programs.29
The MSRB also stated that it has
previously discussed the application of
Rule G–45 to dealers, and in doing so
has said that the activities of an entity
may cause that entity to be within the
definition of dealer and/or underwriter
set forth in the Act or rules thereunder
and thus subject to MSRB Rule G–45.30
The MSRB stated that, for example, the
activities of a program manager to an
ABLE program or 529 college savings
plan, or its affiliates or contractors,
could include direct contact with
investors through the development and
distribution of ABLE program or 529
college savings plan advertising sales
literature, or maintaining ABLE program
or 529 college savings plan websites,
25 Id.
26 Id.
27 See
28 See
SIFMA Letter.
MSRB Response Letter.
including processing enrollment
funds.31 The MSRB stated that those
activities could, depending on the facts
and circumstances, cause one or more of
those entities to be underwriters under
Rule G–45.32 The MSRB also noted that
it believed the Commission has agreed
with the MSRB that each entity must
make its own determination about
whether its activity would qualify as
‘‘underwriting’’ activity as that term is
defined in SEC Rule 15c2–12(f)(8) under
the Act.33 In addition, the MSRB stated
that, beginning in 2015, the MSRB has
received data from underwriters to 529
college savings plans under Rule G–
45.34 The MSRB stated that it has every
reason to believe that there is
widespread compliance by those
underwriters with their reporting
obligations under Rule G–45.35
Consequently, the MSRB stated, it does
not believe that the requirement to
submit fee information, as would be
required under the proposed rule
change, on MSRB Form G–45 would
unduly burden competition between
underwriters to advisor-sold ABLE
programs or 529 college savings plans
versus underwriters to direct-sold ABLE
programs or 529 college savings plans.36
IV. Discussion and Commission
Findings
The Commission has carefully
considered the proposed rule change,
the comment letter received, and the
MSRB Response Letter. The
Commission finds that the proposed
rule change is consistent with the
requirements of the Act and the rules
and regulations thereunder applicable to
the MSRB.
In particular, the proposed rule
change is consistent with Sections
15B(b)(2)(C) of the Act.41 Section
15B(b)(2)(C) of the Act states that the
MSRB’s rules shall be designed to
prevent fraudulent and manipulative
acts and practices, to promote just and
equitable principles of trade, to foster
cooperation and coordination with
persons engaged in regulating, clearing,
settling, processing information with
respect to, and facilitating transactions
in municipal securities and municipal
financial products, to remove
impediments to and perfect the
mechanism of a free and open market in
municipal securities and municipal
financial products, and, in general, to
3. Underwriter Reporting Obligation
protect investors, municipal entities,
obligated persons, and the public
SIFMA stated that it believed dealers
42
that underwrite ABLE programs and 529 interest. The Commission believes the
proposed rule change is consistent with
college savings plans should only be
required to submit information required Section 15B(b)(2)(C) and necessary and
appropriate to help the MSRB receive
by MSRB Form G–45 to the extent that
complete and reliable information about
such information is within their
ABLE programs and 529 college savings
37 The
possession, custody and control.
plans which it can use to monitor such
MSRB stated that, under the proposed
programs and plans and detect potential
rule change, and consistent with the
MSRB’s previous position on this issue, investor harm. The Commission
believes that, for that data set to be
an underwriter to an ABLE program or
complete and reliable, such data should
529 college savings plan would not be
include the data about the fees and
required to submit information on
expenses associated with an investment
MSRB Form G–45 that the underwriter
neither possesses nor has the legal right in an ABLE program or a 529 college
savings plan that are included in the
to obtain.38 The MSRB also noted that
proposed rule change. In addition, the
the legal right to obtain the information
Commission believes the proposed rule
for purposes of the proposed rule
change is necessary for the MSRB to
change is not affected by a voluntary
gather relevant data required to ensure
relinquishment, by contract or
otherwise, of such right.39 Therefore, the the MSRB’s regulatory scheme is
sufficient and/or to determine whether
MSRB stated, an underwriter may
additional rulemaking is necessary to
designate an affiliate or contractor to
protect investors and the public interest.
perform activities in the underwriter’s
The Commission believes that the
stead in connection with the
proposed rule change would facilitate
underwriting, but that the underwriter
the MSRB’s ability to better analyze the
market for ABLE programs and 529
31 Id.
college savings plans as well as improve
32 Id.
the MSRB’s ability to evaluate trends
33 Id.
and differences among ABLE programs
34 Id.
35 Id.
and 529 college savings plans. Further,
36 Id.
37 See
29 Id.
38 See
30 Id.
SIFMA Letter.
MSRB Response Letter.
39 Id.
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21:28 Dec 13, 2017
would be properly viewed as having the
legal right to obtain all information.40
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Frm 00359
40 Id.
41 15
42 15
Fmt 4703
Sfmt 4703
E:\FR\FM\14DEN1.SGM
U.S.C. 78o–4(b)(2)(C).
U.S.C. 78o–4(b)(2)(C).
14DEN1
Federal Register / Vol. 82, No. 239 / Thursday, December 14, 2017 / Notices
the Commission believes that the MSRB,
as well as other financial regulators
charged with enforcing the MSRB’s
rules, use (or will use) the information
submitted on MSRB Form G–45 to
enhance their understanding of, and
ability to monitor, ABLE programs and
529 college savings plans.
The Commission believes that the
MSRB or other regulators could use the
information submitted on MSRB Form
G–45 to, among other things, determine
if the disclosure documents or
marketing materials prepared or
reviewed by underwriters are consistent
with the data submitted to the MSRB for
regulatory purposes.
In approving the proposed rule
change, the Commission also has
considered the impact of the proposed
rule change on efficiency, competition,
and capital formation.43 The
Commission does not believe that the
proposed rule change will impose any
burden on competition not necessary or
appropriate in furtherance of the
purposes of the Act. The additional data
that the proposed rule change would
collect is understood by the
Commission to be readily available and
known to the underwriters of ABLE
programs and 529 college savings plans.
Additionally, the Commission
understands that these underwriters are
already required to submit certain
information to the MSRB on MSRB
Form G–45 on a semi-annual basis.
Also, the Commission believes that the
additional information required to be
submitted by the proposed rule change
would be submitted on an equal and
non-discriminatory basis, and the
requirement would apply equally to all
dealers that serve as underwriters to
ABLE programs and/or 529 college
savings plans. Furthermore, the
Commission believes that the potential
burdens created by the proposed rule
change are to be likely outweighed by
the benefits.
For the reasons noted above, the
Commission believes that the proposed
rule change is consistent with the Act.
sradovich on DSK3GMQ082PROD with NOTICES
V. Conclusion
It is therefore ordered, pursuant to
Section 19(b)(2) of the Act,44 that the
proposed rule change (SR–MSRB–2017–
08) be, and hereby is, approved.
For the Commission, pursuant to delegated
authority.45
Eduardo A. Aleman,
Assistant Secretary.
[FR Doc. 2017–26909 Filed 12–13–17; 8:45 am]
BILLING CODE 8011–01–P
43 15
U.S.C. 78c(f).
U.S.C. 78s(b)(2).
45 17 CFR 200.30–3(a)(12).
44 15
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21:28 Dec 13, 2017
Jkt 244001
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–82251; File No. SR–CHX–
2017–08]
Self-Regulatory Organizations;
Chicago Stock Exchange, Inc.; Notice
of Filing of Amendment No. 1 to a
Proposed Rule Change To Amend the
Schedule of Fees and Assessments To
Adopt a Fee Schedule To Establish
Fees for Industry Members Related to
the National Market System Plan
Governing the Consolidated Audit Trail
December 8, 2017.
On May 3, 2017, the Chicago Stock
Exchange, Inc. (‘‘CHX’’ or the
‘‘Exchange’’) filed with the Securities
and Exchange Commission
(‘‘Commission’’), pursuant to Section
19(b)(1) of the Securities Exchange Act
of 1934 (‘‘Act’’),1 and Rule 19b–4
thereunder,2 a proposed rule change to
adopt a fee schedule to establish the fees
for Industry Members related to the
National Market System Plan Governing
the Consolidated Audit Trail (the ‘‘CAT
NMS Plan’’). The proposed rule change
was published in the Federal Register
for comment on May 22, 2017.3 The
Commission received seven comment
letters on the proposed rule change,4
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 See Securities Exchange Act Release No. 80691
(May 16, 2017), 82 FR 23344 (May 22, 2017)
(‘‘Original Proposal’’).
4 Since the CAT NMS Plan Participants’ proposed
rule changes to adopt fees to be charged to Industry
Members to fund the consolidated audit trail are
substantively identical, the Commission is
considering all comments received on the proposed
rule changes regardless of the comment file to
which they were submitted. See text accompanying
notes 13–16 infra, for a list of the CAT NMS Plan
Participants. See Letter from Theodore R. Lazo,
Managing Director and Associate General Counsel,
Securities Industry and Financial Markets
Association, to Brent J. Fields, Secretary,
Commission (dated June 6, 2017), available at:
https://www.sec.gov/comments/sr-batsbzx-2017-38/
batsbzx201738-1788188-153228.pdf; Letter from
Patricia L. Cerny and Steven O’Malley, Compliance
Consultants, to Brent J. Fields, Secretary,
Commission (dated June 12, 2017), available at:
https://www.sec.gov/comments/sr-cboe-2017-040/
cboe2017040-1799253-153675.pdf; Letter from
Daniel Zinn, General Counsel, OTC Markets Group
Inc., to Eduardo A. Aleman, Assistant Secretary,
Commission (dated June 13, 2017), available at:
https://www.sec.gov/comments/sr-finra-2017-011/
finra2017011-1801717-153703.pdf; Letter from
Joanna Mallers, Secretary, FIA Principal Traders
Group, to Brent J. Fields, Secretary, Commission
(dated June 22, 2017), available at: https://
www.sec.gov/comments/sr-cboe-2017-040/
cboe2017040-1819670-154195.pdf; Letter from
Stuart J. Kaswell, Executive Vice President and
Managing Director, General Counsel, Managed
Funds Association, to Brent J. Fields, Secretary,
Commission (dated June 23, 2017), available at:
https://www.sec.gov/comments/sr-finra-2017-011/
finra2017011-1822454-154283.pdf; and Letter from
Suzanne H. Shatto, Investor, to Commission (dated
June 27, 2017), available at: https://www.sec.gov/
2 17
PO 00000
Frm 00360
Fmt 4703
Sfmt 4703
59151
and a response to comments from the
Participants.5 On June 30, 2017, the
Commission temporarily suspended and
initiated proceedings to determine
whether to approve or disapprove the
proposed rule change.6 The Commission
thereafter received seven comment
letters,7 and a response to comments
from the CAT NMS Plan Participants.8
On November 9, 2017, the Exchange
filed Amendment No. 1 to the proposed
rule change, as described in Items I and
II below, which Items have been
prepared by the Exchange.9 On
November 9, 2017, the Commission
extended the time period within which
to approve the proposed rule change or
disapprove the proposed rule change to
comments/sr-batsedgx-2017–22/batsedgx201722154443.pdf. The Commission also received a
comment letter which is not pertinent to these
proposed rule changes. See Letter from Christina
Crouch, Smart Ltd., to Brent J. Fields, Secretary,
Commission (dated June 5, 2017), available at:
https://www.sec.gov/comments/sr-batsbzx-2017-38/
batsbzx201738-1785545-153152.htm.
5 See Letter from CAT NMS Plan Participants to
Brent J. Fields, Secretary, Commission (dated June
29, 2017), available at: https://www.sec.gov/
comments/sr-batsbyx-2017-11/batsbyx2017111832632-154584.pdf.
6 See Securities Exchange Act Release No. 81067
(June 30, 2017), 82 FR 31656 (July 7, 2017).
7 See Letter from W. Hardy Callcott, Partner,
Sidley Austin LLP, to Brent J. Fields, Secretary,
Commission (dated July 27, 2017), available at:
https://www.sec.gov/comments/sr-batsbyx-2017-11/
batsbyx201711-2148338-157737.pdf; Letter from
Kevin Coleman, General Counsel and Chief
Compliance Officer, Belvedere Trading LLC, to
Brent J. Fields, Secretary, Commission (dated July
28, 2017), available at: https://www.sec.gov/
comments/sr-batsbyx-2017-11/batsbyx2017112148360-157740.pdf; Letter from Joanna Mallers,
Secretary, FIA Principal Traders Group, to Brent J.
Fields, Secretary, Commission (dated July 28, 2017),
available at: https://www.sec.gov/comments/srbatsbyx-2017-11/batsbyx201711-2151228157745.pdf; Letter from Theodore R. Lazo,
Managing Director and Associate General Counsel,
SIFMA, to Brent J. Fields, Secretary, Commission
(dated July 28, 2017), available at: https://
www.sec.gov/comments/sr-batsbyx-2017-11/
batsbyx201711-2150977-157744.pdf; Letter from
Stuart J. Kaswell, Executive Vice President and
Managing Director, General Counsel, Managed
Funds Association, to Brent J. Fields, Secretary,
Commission (dated July 28, 2017), available at:
https://www.sec.gov/comments/sr-batsbyx-2017-11/
batsbyx201711-2150818-157743.pdf; Letter from
John Kinahan, Chief Executive Officer, Group One
Trading, L.P., to Brent J. Fields, Secretary,
Commission (dated August 10, 2017), available at:
https://www.sec.gov/comments/sr-finra-2017-011/
finra2017011-2214568-160619.pdf; Letter from
Joseph Molluso, Executive Vice President and CFO,
Virtu Financial, to Brent J. Fields, Commission
(dated August 18, 2017), available at: https://
www.sec.gov/comments/sr-finra-2017-011/
finra2017011-2238648-160830.pdf.
8 See Letter from Michael Simon, Chair, CAT
NMS Plan Operating Committee, to Brent J. Fields,
Commission, Secretary (dated November 2, 2017),
available at https://www.sec.gov/comments/srbatsbyx-2017-11/batsbyx201711-2674608161412.pdf.
9 Amendment No. 1 to the proposed rule change
replaces and supersedes the Original Proposal in its
entirety.
E:\FR\FM\14DEN1.SGM
14DEN1
Agencies
[Federal Register Volume 82, Number 239 (Thursday, December 14, 2017)]
[Notices]
[Pages 59148-59151]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2017-26909]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-82238; File No. SR-MSRB-2017-08]
Self-Regulatory Organizations; Municipal Securities Rulemaking
Board; Order Granting Approval of a Proposed Rule Change To Amend MSRB
Form G-45 To Collect Additional Data About the Transactional Fees
Primarily Assessed by Programs Established To Implement the ABLE Act
December 8, 2017.
I. Introduction
On October 13, 2017, the Municipal Securities Rulemaking Board (the
``MSRB'' or ``Board'') filed with the Securities and Exchange
Commission (the ``SEC'' or ``Commission''), pursuant to Section
19(b)(1) of the Securities Exchange Act of 1934 (``Act'') \1\ and Rule
19b-4 thereunder,\2\ a proposed rule change to amend MSRB Form G-45
under MSRB Rule G-45, on reporting of information on municipal fund
securities,\3\ to collect additional data about the transactional fees
primarily assessed by programs established to implement the Stephen
Beck, Jr., Achieving a Better Life Experience Act of 2014 (the ``ABLE
Act'' and an ``ABLE program'') (the ``proposed rule change'').\4\ The
proposed rule change
[[Page 59149]]
was published for comment in the Federal Register on October 27,
2017.\5\
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\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ Form G-45 is an electronic form on which submissions of the
information required by Rule G-45 are made to the MSRB.
\4\ The ABLE Act was enacted on December 19, 2014 as part of The
Tax Increase Prevention Act of 2014 (Pub. L. 113-295).
\5\ Securities Exchange Act Release No. 81921 (October 23, 2017)
(the ``Notice of Filing''), 82 FR 49908 (October 27, 2017).
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The Commission received one comment letter on the proposed rule
change.\6\ On December 1, 2017, the MSRB responded to the comments
received by the Commission.\7\
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\6\ See Letter to Secretary, Commission, from Leslie Norwood,
Managing Director and Associate General Counsel, and Bernard Canepa,
Vice President and Assistant General Counsel, Securities Industry
and Financial Markets Association (``SIFMA''), dated November 17,
2017 (the ``SIFMA Letter'').
\7\ See Letter to Secretary, Commission, from Pamela K. Ellis,
Associate General Counsel, MSRB, dated December 1, 2017 (the ``MSRB
Response Letter''), available at https://www.sec.gov/comments/sr-msrb-2017-08/msrb201708-2743045-161576.pdf .
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II. Description of Proposed Rule Change
In the Notice of Filing, the MSRB stated that the proposed rule
change would amend Form G-45 to collect additional information relating
to fees and expenses to help ensure that the MSRB continues to receive
comprehensive information regarding ABLE programs and 529 college
savings plans.\8\ The MSRB stated that this data would enhance the
MSRB's understanding of the markets for ABLE programs and 529 college
savings plans, including the differences among such programs or
plans.\9\ Further, the MSRB stated that the additional fee and expense
information would assist the MSRB in fulfilling its investor protection
mission.\10\ The MSRB also stated that the information about fees and
expenses would continue to be submitted in a format that is consistent
with the disclosure principles of the College Savings Plan Network
(``CSPN''), an affiliate of the National Association of State
Treasurers, which, the MSRB added, commenters on previous MSRB
rulemaking proposals relating to MSRB Form G-45 have stated is the
industry norm.\11\
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\8\ See Notice of Filing.
\9\ Id.
\10\ Id.
\11\ Id.
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As further described by the MSRB in the Notice of Filing, under the
proposed rule change, an underwriter to an ABLE program or a 529
college savings plan would be required to submit data on Form G-45
about the following additional fees and expenses, as applicable:
account opening fee;
investment administration fee;
change in account owner fee;
cancellation/withdrawal fee;
change in investment option/transfer fee;
rollover fee;
returned excess aggregate contributions fee;
rejected ACH or EFT fee;
overnight delivery fee;
in-network ATM fee;
out-of-network ATM fee;
ATM mini statement fee;
international POS/ATM transaction fee;
foreign transaction fee;
overdraft fee;
copy of check or statement fee (per request);
copy of check images mailed with monthly statement fee;
check fee (i.e., fee for blank checks);
returned check fee;
checking account option fee;
re-issue of disbursement check fee;
stop payment fee;
debit card fee;
debit card replacement fee;
outgoing wire fee;
expedited debit card rush delivery fee;
paper fee; and
miscellaneous fee (to address any miscellaneous
transactional fee that is not otherwise specified on Form G-45).\12\
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\12\ Id.
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In addition, under the proposed rule change, the MSRB stated that
it would collect data about any variance in the annual account
maintenance fee due to the residency of the account owner.\13\ The MSRB
also stated that the proposed rule would apply to underwriters to ABLE
programs as well as to underwriters to 529 college savings plans.\14\
The MSRB, however, stated that it anticipates that most of the data
that would be collected by the proposed rule change would relate to
ABLE programs.\15\ The MSRB also noted that it believes that 529
college savings plans generally do not assess the fees and charges that
are the subject of this proposed rule change.\16\
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\13\ Id.
\14\ Id.
\15\ Id.
\16\ Id.
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The MSRB requested in the Notice of Filing that the proposed rule
change be approved with an effective date of June 30, 2018.\17\
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\17\ Id.
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III. Summary of Comments Received and MSRB's Responses to Comments
As noted previously, the Commission received one comment letter on
the proposed rule change, as well as the MSRB Response Letter. The
commenter, SIFMA, stated that it was ``supportive of the MSRB's efforts
to fully understand the ABLE programs and 529 college savings plans
market and fulfill its mission'' but believed that municipal securities
dealers who underwrite ABLE programs and 529 college savings plans
``should only be required to submit the information required by Form G-
45 to the extent it is within their possession, custody, or
control''.\18\ SIFMA also stated that the MSRB should be mindful of the
possibility that additional regulatory requirements such as the
proposed rule change could increase costs to investors in dealer-sold
529 college savings plans and ABLE programs versus direct-sold programs
that are not regulated by the MSRB.\19\ The MSRB stated that it
believes the proposed rule change is consistent with its statutory
mandate and has responded to the comments, as discussed below.\20\
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\18\ See SIFMA Letter.
\19\ Id.
\20\ See MSRB Response Letter.
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1. Submission of Information Within Custody of Dealer
SIFMA stated that some of the information about fees that
underwriters would be required to submit on MSRB Form G-45, under the
proposed rule change, may be contained in ABLE program or 529 college
savings plan disclosure documents and suggested that those underwriters
could provide hyperlinks to those documents to the MSRB.\21\ The MSRB
responded by stating that even if some of the information required to
be submitted on MSRB Form G-45 were contained in those ABLE program or
529 college savings plan disclosure documents, that the information
would not be published in a uniform electronic format that would allow
for the MSRB's efficient analysis or comparison of such
information.\22\ The MSRB noted that, at this time, there is no
requirement that state issuers prepare those disclosure documents in a
uniform format and, unlike for 529 college savings plans, there are not
even voluntary disclosure principles for state issuers in the
preparation of their disclosure documents that are applicable to ABLE
programs.\23\ As result, the MSRB stated, it is even more likely that
the information in the ABLE program disclosure documents would not be
presented in a uniform format that would allow the MSRB to readily
analyze and compare ABLE programs.\24\ In addition, the MSRB stated
that referencing the ABLE program or 529
[[Page 59150]]
college savings plan disclosure documents would not meet the MSRB's
regulatory need because the data provided to the MSRB must be in a
uniform electronic format that can be aggregated and analyzed.\25\ The
MSRB acknowledged that the proposed rule change would result in some
up-front costs to underwriters due to technical changes to
underwriters' reporting systems, but the MSRB stated that those costs
should mostly be one-time only costs and that the cumulative benefits
of receiving data in a uniform electronic format should exceed the
upfront costs over time.\26\
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\21\ See SIFMA Letter.
\22\ See MSRB Response Letter.
\23\ Id.
\24\ Id.
\25\ Id.
\26\ Id.
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2. Applicability of Proposed Rule Change to Advisor-Sold and Direct-
Sold ABLE Programs and 529 College Savings Plans
SIFMA suggested that the duty to submit information about the fees
assessed by ABLE programs and 529 college savings plans on MSRB Form G-
45 would create an undue burden because, in SIFMA's view, the MSRB's
jurisdiction is limited to underwriters to dealer-sold ABLE programs or
529 college savings plans.\27\ The MSRB responded by stating that such
an undue burden on competition would not exist because the MSRB
believes it has jurisdiction over all underwriters of ABLE programs and
529 college savings plans.\28\ The MSRB stated that it has jurisdiction
over underwriters to all 529 college savings plans, regardless of the
marketing channel through which such plans are sold (whether sold with
the advice of a dealer, i.e., ``advisor-sold,'' or without the advice
of a dealer, i.e., ``direct-sold''), and this view has equal
application to similar ABLE programs.\29\ The MSRB also stated that it
has previously discussed the application of Rule G-45 to dealers, and
in doing so has said that the activities of an entity may cause that
entity to be within the definition of dealer and/or underwriter set
forth in the Act or rules thereunder and thus subject to MSRB Rule G-
45.\30\ The MSRB stated that, for example, the activities of a program
manager to an ABLE program or 529 college savings plan, or its
affiliates or contractors, could include direct contact with investors
through the development and distribution of ABLE program or 529 college
savings plan advertising sales literature, or maintaining ABLE program
or 529 college savings plan websites, including processing enrollment
funds.\31\ The MSRB stated that those activities could, depending on
the facts and circumstances, cause one or more of those entities to be
underwriters under Rule G-45.\32\ The MSRB also noted that it believed
the Commission has agreed with the MSRB that each entity must make its
own determination about whether its activity would qualify as
``underwriting'' activity as that term is defined in SEC Rule 15c2-
12(f)(8) under the Act.\33\ In addition, the MSRB stated that,
beginning in 2015, the MSRB has received data from underwriters to 529
college savings plans under Rule G-45.\34\ The MSRB stated that it has
every reason to believe that there is widespread compliance by those
underwriters with their reporting obligations under Rule G-45.\35\
Consequently, the MSRB stated, it does not believe that the requirement
to submit fee information, as would be required under the proposed rule
change, on MSRB Form G-45 would unduly burden competition between
underwriters to advisor-sold ABLE programs or 529 college savings plans
versus underwriters to direct-sold ABLE programs or 529 college savings
plans.\36\
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\27\ See SIFMA Letter.
\28\ See MSRB Response Letter.
\29\ Id.
\30\ Id.
\31\ Id.
\32\ Id.
\33\ Id.
\34\ Id.
\35\ Id.
\36\ Id.
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3. Underwriter Reporting Obligation
SIFMA stated that it believed dealers that underwrite ABLE programs
and 529 college savings plans should only be required to submit
information required by MSRB Form G-45 to the extent that such
information is within their possession, custody and control.\37\ The
MSRB stated that, under the proposed rule change, and consistent with
the MSRB's previous position on this issue, an underwriter to an ABLE
program or 529 college savings plan would not be required to submit
information on MSRB Form G-45 that the underwriter neither possesses
nor has the legal right to obtain.\38\ The MSRB also noted that the
legal right to obtain the information for purposes of the proposed rule
change is not affected by a voluntary relinquishment, by contract or
otherwise, of such right.\39\ Therefore, the MSRB stated, an
underwriter may designate an affiliate or contractor to perform
activities in the underwriter's stead in connection with the
underwriting, but that the underwriter would be properly viewed as
having the legal right to obtain all information.\40\
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\37\ See SIFMA Letter.
\38\ See MSRB Response Letter.
\39\ Id.
\40\ Id.
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IV. Discussion and Commission Findings
The Commission has carefully considered the proposed rule change,
the comment letter received, and the MSRB Response Letter. The
Commission finds that the proposed rule change is consistent with the
requirements of the Act and the rules and regulations thereunder
applicable to the MSRB.
In particular, the proposed rule change is consistent with Sections
15B(b)(2)(C) of the Act.\41\ Section 15B(b)(2)(C) of the Act states
that the MSRB's rules shall be designed to prevent fraudulent and
manipulative acts and practices, to promote just and equitable
principles of trade, to foster cooperation and coordination with
persons engaged in regulating, clearing, settling, processing
information with respect to, and facilitating transactions in municipal
securities and municipal financial products, to remove impediments to
and perfect the mechanism of a free and open market in municipal
securities and municipal financial products, and, in general, to
protect investors, municipal entities, obligated persons, and the
public interest.\42\ The Commission believes the proposed rule change
is consistent with Section 15B(b)(2)(C) and necessary and appropriate
to help the MSRB receive complete and reliable information about ABLE
programs and 529 college savings plans which it can use to monitor such
programs and plans and detect potential investor harm. The Commission
believes that, for that data set to be complete and reliable, such data
should include the data about the fees and expenses associated with an
investment in an ABLE program or a 529 college savings plan that are
included in the proposed rule change. In addition, the Commission
believes the proposed rule change is necessary for the MSRB to gather
relevant data required to ensure the MSRB's regulatory scheme is
sufficient and/or to determine whether additional rulemaking is
necessary to protect investors and the public interest.
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\41\ 15 U.S.C. 78o-4(b)(2)(C).
\42\ 15 U.S.C. 78o-4(b)(2)(C).
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The Commission believes that the proposed rule change would
facilitate the MSRB's ability to better analyze the market for ABLE
programs and 529 college savings plans as well as improve the MSRB's
ability to evaluate trends and differences among ABLE programs and 529
college savings plans. Further,
[[Page 59151]]
the Commission believes that the MSRB, as well as other financial
regulators charged with enforcing the MSRB's rules, use (or will use)
the information submitted on MSRB Form G-45 to enhance their
understanding of, and ability to monitor, ABLE programs and 529 college
savings plans.
The Commission believes that the MSRB or other regulators could use
the information submitted on MSRB Form G-45 to, among other things,
determine if the disclosure documents or marketing materials prepared
or reviewed by underwriters are consistent with the data submitted to
the MSRB for regulatory purposes.
In approving the proposed rule change, the Commission also has
considered the impact of the proposed rule change on efficiency,
competition, and capital formation.\43\ The Commission does not believe
that the proposed rule change will impose any burden on competition not
necessary or appropriate in furtherance of the purposes of the Act. The
additional data that the proposed rule change would collect is
understood by the Commission to be readily available and known to the
underwriters of ABLE programs and 529 college savings plans.
Additionally, the Commission understands that these underwriters are
already required to submit certain information to the MSRB on MSRB Form
G-45 on a semi-annual basis. Also, the Commission believes that the
additional information required to be submitted by the proposed rule
change would be submitted on an equal and non-discriminatory basis, and
the requirement would apply equally to all dealers that serve as
underwriters to ABLE programs and/or 529 college savings plans.
Furthermore, the Commission believes that the potential burdens created
by the proposed rule change are to be likely outweighed by the
benefits.
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\43\ 15 U.S.C. 78c(f).
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For the reasons noted above, the Commission believes that the
proposed rule change is consistent with the Act.
V. Conclusion
It is therefore ordered, pursuant to Section 19(b)(2) of the
Act,\44\ that the proposed rule change (SR-MSRB-2017-08) be, and hereby
is, approved.
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\44\ 15 U.S.C. 78s(b)(2).
For the Commission, pursuant to delegated authority.\45\
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\45\ 17 CFR 200.30-3(a)(12).
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Eduardo A. Aleman,
Assistant Secretary.
[FR Doc. 2017-26909 Filed 12-13-17; 8:45 am]
BILLING CODE 8011-01-P